AQ_F_0400039_20211116_PRMT_FnlAppPkg

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AgriBusinessm
Environmental Services & Sustainability
www.perdueagribusiness.comO
November 15, 2021 RECEIVED
Heather Carter NOV 16 2021
Regional Supervisor
Fayetteville Regional Office
Division of Air Quality, NC DEQ DEO-FAYMEVILLERMORALOFFICE
225 Green Street, Suite 714,
Fayetteville, NC 28301-5095
RE: Response to Notice of Violation and Submittal of Permit Application
Perdue AgriBusiness
Ansonville, NC
Facility ID:06/04-00039
Permit No.07495R09
Ms. Carter:
Perdue AgriBusiness (Perdue) is submitting the attached application in response to the Notice of
Violation (NOV) letter received on October 16, 2021. Per previous conversations between Perdue
and DAQ, Perdue stated that the facility treats the feed with a material called Termin - 8® which
contains methanol and formaldehyde. Based on initial information from the vendor the amount of
formaldehyde that could potentially be released was 2%.
In further discussions with the vendor, Anitox, they perform readily available and easily reproducible
tests that yield results showing 98% of the formaldehyde is bound in the product. Per the vendor,
these tests provide conservative estimates since they are not precise tests. Anitox has performed
further testing in a lab-based setting with a more precise method that yields results showing that as
much as 99.95% (0.05% released) of the formaldehyde is bound to the feed. Information provided
from the vendor is found in Appendix B of the attached permit application. The operations at
Ansonville are mixing and blending only. The material is processed at ambient temperatures and
not heated as in pellet coolers found at other feed mill operations utilizing Termin-8 ®. Perdue has
utilized the updated vendor information regarding 0.05% release and has estimated potential
releases using this information.
The NOV letter requests an evaluation of NC Air Toxics rule 15A NCAC 02Q .0711 for formaldehyde.
Using the following parameters, the amount of formaldehyde estimated to be released is 0.07 lb/hr.
• 70 tons of feed/hr throughput rate
• 6 lb of Termin - 8®/ton of feed
• 33% formaldehyde
• 0.05% release rate
We Believe In Responsible Food and Agriculture®

The Termin - 8® is added in an enclosed mixer and sent to storage bins all contained within the
mixing building. Since the emissions are not vented through a specific stack, Perdue compared the
emission rates to the Toxics Permitting Emission Rate (TPER) for obstructed sources found in 15A
NCAC 02Q .0711(a), which is 0.04 lb/hr. Therefore, a modeling demonstration was performed and
is included in Section 4 of the attached permit application. The modeling analysis was conducted
using normalized emission rates in order to determine a facility-wide allowable emission rate. An
emission rate of 1.46 Ib/hr was developed at 99% of the ambient air levels (AAL) for formaldehyde.
Please feel free to contact Joey Baggett of Perdue at [phone] or Dana Norvell of Trinity
Consultants at [phone] if you have any questions on this submittal.
Sincerely,
S han.M
Sharon Clark
Perdue AgriBusiness
SVP Regulatory Affairs &Compliance
cc: Joey Baggett - Perdue
Dana Norvell, P.E. —Trinity Consultants

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CONSTRUCTION PERMIT APPLICATION
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Perdue Agribusiness
Ansonville, NC
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Prepared By:
TRINITY CONSULTANTS
One Copley Parkway, Suite 205
Morrisville, NC 27560
919 462 9693
I November 2021
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Project 213401.0120
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TABLE OF CONTENTS
1. INTRODUCTION 1-1
1.1 Executive Summary..........................................................................................1-1
1.2 Application Contents........................................................................................1-1
2. PROJECT DESCRIPTION 2-1
2.1 Facility Operations............... ......2-1
2.2 Permitting History............................................................................................2-1
I2.3 Project Description...........................................................................................2-1
3. REGULATORY APPLICABILITY ANALYSIS 3-1
3.1 Title V Applicability...........................................................................................3-1
.2 New Source Review................................................. .......................................3-1
3.3 NSPS Applicability............................................................................................3-1
3.4 NESHAP Applicability.................... ...................3-2
3.4.1 40 CFR 63, Subpart DDDDDDD(7D)-NESHAP Area Source Standards for
Prepared Feeds Manufacturing...................................................................................3 2
3.5 North Carolina Regulations..............................................................................3-2
3.5.1 Particulate Control Requirement 15A NCAC 2D.0515 3 2
3.5.2 Control of Visible Emissions(15A NCAC 2D.0521)............................................3 2
3.6 State Only Rules...............................................................................................3-3
3.6.1 15A NCAC 2D.1806-Control of Odors...........................................................3 3
3.6.2 15A NCAC 2D.1100-Control of Toxic Air Pollutants........................................3-3
16.3 15A NCAC 2Q.0700- Toxic Air Pollutant Procedures........................................3-3
4. DISPERSION MODELING ANALYSIS 4-1
4.1 Introduction.....................................................................................................4-1
4.2 Site Description.........................
4.3 Modeled Sources and Stack Parameters .........4-1
4.4 Model Setup and Data Resources.....................................................................4-1
4.5 Modeling Results..............................................................................................4-4
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S. GENERAL FACILITY PERMIT APPLICATION FORMS 5-1
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6. SOURCE SPECIFIC PERMIT APPLICATION FORMS 6-1
APPENDIX A. EMISSION CALCULATIONS A
APPENDIX B.VENDOR INFORMATION B
APPENDIX C. MODELING PROTOCOL C
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Perdue Ansonville, NC
Construction Permit Application i Trinity Consultants
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1. INTRODUCTION
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1.1 Executive Summary
Perdue Agribusiness (Perdue) owns and operates a blending operation in Ansonville, NC(Facility
ID#: 0400039) under SIC Code 2048. The facility currently operates under North Carolina
Department of Environmental Quality, Division of Air Quality (NCDAQ)Air Permit No. 07495R09. The
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facility is classified as a small facility.
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Perdue is submitting this application to request permit updates including source description changes,
removal of a federal standard and use of a material containing hazardous air pollutants (HAPs) and
a North Carolina Toxic Air Pollutant (TAP).
For the proposed changes, Perdue is requesting a construction and operating permit be issued in
accorda
nce with Title 15A of North Carolina Administrative Code (15A NCAC) Chapter 2Q .0304 and
2Q.0305. In accordance with 15A NCAC 2Q .0305(b)(1), the required two (2) copies of the
application have been included, and the copy has been signed as required by Rule
2Q.0305(a)(1)(E).
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The facility will remain a small facility for criteria emissions and an area source of hazardous air
pollutants (HAPs) with the approval of this application. Therefore, the permit application fee for a
small facility ($50) will be submitted by e-payment as required under 2Q .0304U) and 2Q
.0305(a)(1)(A).
Perdue has not included a zoning consistency determination as required by 2Q.0304(b)(1) and
2Q.0305(a)(1)(B) since there is not any construction or modification of an emission source for this
application.
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1.2 Application Contents
This application for a construction and operating permit contains the following information:
• Section 2 provides facility background and process descriptions for the proposed sources,
• Section 3 provides a federal and state regulatory applicability analysis,
• Section 4 contains the dispersion modeling analysis,
• Section 5 provides the applicable NC general facility permit application forms,
• Section 6 provides source specific permit application forms,
• Appendix A contains potential emission calculations,
• Appendix B contains the vendor information; and
• Appendix C contains the modeling protocol checklist.
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2. PROJECT DESCRIPTION
2.1 Facility Operations
j Perdue owns and operates a blending operation at 2755 Old Hwy 52 West, Ansonville, NC. The
facility is currently operating in accordance with North Carolina Department of Environmental Quality
(DEQ), Division of Air Quality (DAQ), Permit No. 07495R09 issued July 26, 2017, and set to expire
June 30, 2025.
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2.2 Permitting History
The facility is currently permitted as a small minor source and is permitted to operate the following
emission sources:
o No. A - Railcar, choke-fed receiving pit within a two-sided, roofed enclosure
o No. B -Truck receiving pit within a two-sided, roofed enclosure equipped with a
fabric filter CD-4
o No. I—Three storage silos, two with a capacity of 11,300 cubic yards and one with a
capacity of 9,600 cubic yards equipped with two fabric filters CD-3 and CD-5
o No. C— Pneumatic truck receiver
o No. H—Truck load out operation within a three-sided roofed enclosure
o No. J —Mineral Additive Mixing and Handling system
o Insignificant Sources: I-S1 through S3 —Truck loadout spout silos 1-3
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.3 Project Description
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Use of Termin - 89
Perdue is utilizing Termin-8° as an additive to the blending operations.Termin-811 is stored in 2,400
lb totes at the facility.The Termin-8 ® will be applied by atomizing nozzles inside the mixer
(emission source No. J), which is a closed vessel. Termin-8® will introduce new pollutants, methanol
and formaldehyde, to the facility and therefore was evaluated for permitting and NC Toxics.
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j Termin - 8° contains formaldehyde and methanol according to vendor information.The vendor has
performed analytical testing to determine the amount of formaldehyde that is potentially bound to
the feed. In discussions with the vendor, they have performed readily available and easily
it reproducible tests that yielded results that 98% is bound in the product. Anitox has performed
further testing in a lab-based setting with a more precise method that yields results showing that
99.95% (0.05% released) of the formaldehyde is bound to the feed (see vendor information in
Appendix B). The operations at Ansonville are mixing and blending only. The material is processed
i at ambient temperatures and not heated as in other operations that use Termin-8 R� like pellet
coolers. Based on vendor testing, 0.05% of the formaldehyde and 0.28% methanol is not bound to
the feed.
Potential emissions of formaldehyde are above the toxic pollutant emission rate (TPERs) 15A NCAC
2D .0711(a) and as such Perdue has performed a dispersion modeling analysis as provided in
Section 4 of the application.
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Construction Permit Application 2-1 Trinity Consultants

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Updates to the Permit
Two emission sources; No. H and No. J are noted in the current permit as being subject to 40 CFR
63 Subpart DDDDDDD (71)), the National Emissions Standards for Hazardous Air Pollutants
(NESHAP)Area Sources Standards for Prepared Feeds Manufacturing.
Per §63.11619(a) You are subject to this subpart if you own or operate a prepared feeds
manufacturing facility that uses a material containing chromium or a material containing manganese
j and is an area source of emissions of hazardous air pollutants(HAP).
The Perdue Ansonville facility does not use any materials containing chromium or manganese at this
stie and thus is not subject to this standard. Perdue requests to remove applicability to Subpart 7D
from the revised permit.
The control devices as listed in the permit are incorrect and Perdue is requesting to update as part
of this application. The permit currently has emission source No. I -3 storage silos as being controlled
by CD-3 and CD-5. CD-5 is actually installed on emission source No. C—pneumatic truck receiver.The
fabric filter CD-3 is installed on all three storage silos in ID No. I.
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Construction Permit Application 2-2 Trinity Consultants
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3. REGULATORY APPLICABILITY ANALYSIS
3.1 Title V Applicability
40 CFR 70 establishes the federal Title V operating permit program. North Carolina has incorporated
the provisions of this federal program in its Title V operating permit program under 15A NCAC
2Q.0500. The major source thresholds with respect to the North Carolina Title V operating permit
program regulations are 10 TPY of a single HAP, 25 TPY of any combination of HAP, and 100 TPY of
certain other regulated criteria pollutants.
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Perdue is currently classified as small minor stationary source as the classification status pertains to
40 CFR Part 70 (Title V). The potential to emit (PTE) of each criteria pollutant is below 100 ton per
year (TPY). The PTE of each HAP is less than 10 TPY and aggregate HAPs are less than 25 TPY.
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3.2 New Source Review
The NSR permitting program generally requires that a stationary source obtain a permit and
undertake other obligations prior to construction of any facility if the proposed project results in the
potential to emit an air pollution in excess of certain threshold levels. The federal NSR program is
listed in 40 CFR 51.Two distinct NSR permitting programs apply depending on whether the facility is
located in an attainment or nonattainment area for a particular pollutant, PSD and NNSR,
respectively. NNSR permitting applies to new construction or modifications that result in emission
increases of a particular pollutant for which the area in which the facility is located is classified as
"nonattainment". The PSD permitting program applies to projects with emissions increases of
pollutants for which the area is classified as"attainment"or"unclassifiable".
The facility is located in Anson County, which is attainment or unclassifiable with respect to the
National Ambient Air Quality Standards (NAAQS) for all regulated pollutants.' Therefore, with
respect to the NSR permitting program, only PSD requirements are considered to be potentially
applicable to the Ansonville facility.
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Under PSD permitting rules, the major source threshold is 250 TPY unless the facility falls under one
j of the specifically delineated source categories ("List of 28'� as having a lower 100 TPY threshold.
The facility is not on the list of 28 and therefore is a 250 TPY major source.
j The facility is a small source thus emissions are below PSD thresholds and thus PSD is not triggered.
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3.3 NSPS Applicability
New Source Performance Standards (NSPS), located in 40 CFR Part 60 and implemented in North
Carolina Regulation 15A NCAC 2D .0524, require certain categories of new, modified, or
reconstructed sources to control emissions to specified levels.
There are currently no sources subject to New Source Performance Standards at this facility.
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1 40 CFR 81.334
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3.4 NESHAP Applicability
NESHAP are emission standards for HAP and are applicable to major and area sources of HAP. A
HAP major source is defined as having potential emissions in excess of 25 TPY for total HAP and/or
potential emissions in excess of 10 TPY for any individual HAP. An area source is a stationary source
that is not a major source. Part 63 NESHAP allowable emission limits are established on the basis of
a Maximum Achievable Control Technology (MACT) determination for a particular source category.
NESHAP apply to sources in specifically regulated industrial source categories [CAA Section 112(d)]
or on a case-by-case basis Section 112 y [ (g)] for facilities not regulated as a specific industrial source
type.
The Ansonville facility is an area source of HAP emissions.
. . 40 CFR 63, Subpart DDDDDDD QD) — NESHAP Area Source Standards
for Prepared Feeds Manufacturing
Facilities are subject to this rule if they own or operate a prepared feeds manufacturing facility that
uses a material containing chromium or a material contain manganese and is an area source of
HAPs.
The current permit contains the requirements of this standard. However, the facility does not use
any materials containing chromium or manganese. Perdue requests to remove applicability to this
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standard as part of the revised permit.
.5 North Carolina Regulations
j The applicability of key North Carolina State Implementation Plan (SIP) regulations are discussed
below.
. .1 Particulate Control Requirement (15A NCAC 2D.0515)
This regulation outlines control requirements for particulate emissions,through a process weight
rate calculation. For units where the process throughput rate in tons is greater than 30 TPH, the
process rate equation is E = 55 * (P)0-11-40. For units where the process throughput rate in tons is
* 0.67
less than 30 TPH the process rate equation is E — 4.10 P
p q ( )
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This application does not contain any changes which would have any effect on the facilities
compliance with this standard.
3.5.2 Control of Visible Emissions (15A NCAC 2D .0521)
This regulation outlines control requirements for visible emissions. Emission units shall not be more
than 20 percent opacity when averaged over a six-minute period, except that six-minute periods
averaging not more than 87 percent opacity may occur not more than once in any hour nor more
than four times in any 24-hour period.
This application does not contain any changes which would have any effect on the facilities
compliance with this standard.
Perdue Ansonville, NC
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3.6 State Only Rules
3.6.1 15A NCAC 21) .1806 — Control of Odors
(e)Control Requirements The owner or operator of a facility subject to this Rule shall not
operate the facility without implementing management practices or installing and
operating odor control equipment sufficient to prevent odorous emissions from the facility
from causing or contributing to objectionable odors beyond the facility's boundary.
Perdue will continue to comply with this standard.
. ®2 15A NCAC 2 .1100 — Control of Toxic Air Pollutants
Under the NC air toxics program regulations, facility-wide modeling and permitting is required if total
facility-wide emissions of regulated air toxics emitted from non-exem t new or modified emission
tY 9 p
units exceed the toxics de minimis emissions rates a.k.a. TPERS established under the 15A
NCAC 2Q .0700 regulations.
Formaldehyde is emitted from Termin-8® usage as a feed additive. Based on emission estimates,
the emissions of formaldehyde exceed the obstructed TPER of 0.04 lb/hr. As such, Perdue is
j submitting an air dispersion modeling analysis (See Section 4).
15A NCAC 2 .0700 —Toxic Air Pollutant Procedures
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This rule establishes procedures for documenting compliance for a modification that results in an
increase in NC air toxics. Compliance can be demonstrated by:
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1. Documenting that facility wide emissions are below the thresholds in 15A NCAC 2Q .0711
2. Netting to show there has been a no net increase in NC air toxics; or
3. Modeling to document compliance with the ambient levels in 15A NCAC 2D .1100.
Perdue has performed modeling for the formaldehyde emissions exhausted from the mixing area to
document compliance as provided in Section 4.
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Construction Permit Application 3-3 Trinity Consultants

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4. DISPERSION MODELING ANALYSIS
This section describes the methodology, data resources and results of the air dispersion modeling analysis
that was completed to demonstrate that the Perdue Ansonville blending operation is in compliance with NC
TAP regulations.
4.1 Introduction
Perdue is requesting to add Termin-8® as an additive to the blending operations. Termin-01 is stored in
2,400 lb totes at the facility. The Termin-8 ®will be applied by atomizing nozzles inside the mixer (emission
source No. 1), which is a closed vessel. Termin-8® will introduce new pollutants, methanol and
formaldehyde, to the facility and therefore was evaluated for permitting and NC Air Toxics.
Potential emissions of formaldehyde are above the toxic pollutant emission rate (TPERs) 15A NCAC 2D
.0711(a) and as such Perdue has performed this air dispersion modeling analysis in order to demonstrate
I facility-wide model impacts comply with the Acceptable Ambient Level (AAL) set forth in 15 NCAC 02D
.1100.
The modeling methodology utilized in the analysis conforms to the Guidelines for Evaluating the Air Quality
Impacts of Toxic Pollutants in North Carolina(May 2018).2 In lieu of a modeling protocol, a protocol
checklist (Form D6) is provided in Appendix C.
4.2 Site Description
Perdue owns and operates a blending operation at 2755 Old Hwy 52 West, in Ansonville, NC.The mill is
located in Anson County and its approximate Universal Transverse Mercator (UTM) coordinates are 580.1
km easting and 3,894.0 km northing (Zone 17, WGS84 datum). Figure 4-1 shows an aerial map of the mill
location and surroundings.
Terrain surrounding the mill is sloped gradually, with some terrain features both above and below the base
elevation of the mill (approximately 248 feet above mean sea level (msl)). Terrain within 2 km of the mill
extends above the lowest stack top elevation. Therefore, terrain heights were identified for all receptors
input to the dispersion model.
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For modeling purposes, the appropriate land use classification for the area was determined as rural based
on a review of topographic maps and guidance provided in the Guidelines
............................................_...........................---._._..._....._.__._._._._.�_
z https://files.nc.gov/ncdeq/Air%20Quality/permits/mets/NC Toxics Guidance_rev_24May2018.pdf
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Perdue Ansonville, NC
Construction Permit Application 4-1 Trinity Consultants
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Figure 4-1.Area Map of Perdue Ansonville and Surroundings
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52
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Perdue Ansonville, NC
Construction Permit Application 4-2 Trinity Consultants
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4.3 Modeled Sources and Stack Parameters
As discussed previously in this application, the addition of Termin-8®to the process results in
formaldehyde emissions coming within the mixing building. Since the emissions occur indoors, the
building was modeled as a volume source with dimensions based on the building footprint(effective
side length 57 feet, height 130 feet).
Table 4-1 and 4-2 summarize the modeled locations and source parameters included in the analysis.
The source was modeled with a normalized emission rate (1 g/s) in order to determine a facility-
wide allowable emission limit for the permit.
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Table 4-1. Modeled Source Locations
Model UTM-E UTM-N Elevation
ID Description (m) (m) (m)
BLDGFUG Mixing Building Fugitives 580,113.3 3,893,971.2 75.7
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Table 4-2. Modeled Source Parameters
Release Init.Lat. Init.Vert.
j Model Height Dimension Dimension
ID (m) (m) (m)
BLDGFUG 19.81 4.04 18.43
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4.4 Model Setup and Data Resources
The latest AERMOD dispersion model (version 21112) was selected to calculate ambient
concentrations at receptor locations off property as well as evaluate whether the cavity re-circulation
zone extends off-property. AERMOD is the NC DAQ-preferred model for most refined modeling
applications. AERMOD includes algorithms to calculate concentrations in the cavity re-circulation
zone, which eliminates the need to use SCREEN3 for evaluation of cavity zones. AERMOD is also
able to estimate impacts at simple, intermediate, and complex terrain receptors, thus eliminating the
need to use multiple dispersion models for the analysis.
Receptors at 25-m spacing were placed along the property boundary of the mill. Beyond the
property boundary, a Cartesian receptor grid with a receptor spacing of 100-m extending
approximately 2 km from the mill in all directions was included (as shown in Figure 4-1). Modeled
impacts were reviewed to ensure that the maximum concentrations were captured within the
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receptor grid.
Terrain elevations for each receptor were identified using the latest AERMAP preprocessor(version
j 18081) and USGS National Elevation Data (NED) digital elevation data with 1 aresecond
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(approximately 30 m) resolution. AERMAP was also used to identify the base elevations for all stacks
and structures input to the model.
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Per the recent Air Quality Analysis Branch guidance for facilities located in Anson County, modeling
was performed using Monroe (EQY) surface and Greensboro (GSO) upper-air meteorological data.3
AERMOD-ready meteorological files processed with AERMET (version 18081) were downloaded from
the NC DAQ webpage for use in this analysis. Preliminary modeling indicated that maximum impacts
were occurring during the early morning hours with very light winds and stable conditions. As such,
the modeling was conducted using meteorological data processed with the EPA-approved, ADJ_U*
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option. The ADJ_U* files were provided by via email by NC DAQ.4
The base elevation of the EQY meteorological site (207.0 m) was used for the potential temperature
profile calculations.5 Five years (2014-2018) of data were used to conservatively estimate the
maximum modeled impacts from the mill. The five years of data were merged since formaldehyde
has a short-term AAL.
The modeled stacks are all below the formula Good Engineering Practice (GEP) stack height;
therefore building downwash parameters were required for the AERMOD analysis. Building
dimensions and stack locations were entered into the BPIP PRIME (version 04274) in order to
develop the required direction specific downwash parameters.
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3 https://files.nc.gov/ncdeq/Air%20QuaIity/permits/mets/met_Stations_by_county.pdf
4 Email from Mark Yoder(NCDAQ)to Jonathan Hill (Trinity)on May 5, 2021.
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5 https://deq.nc.gov/media/10660/download
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Figure 4-2. Modeled Receptor Locations
3,896,000 +
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3,895,500 +++++++++++++++++++++++++++
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3,895,000 +++++++++++++++++++++++++++++++++++
+++++.+++++++++++++++++++++++++++++
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M ++++++++++++++++ ++++++++++++++++++++++
q 3,894,500 +++++++++++++++ +++++++++++++++++++++
z +++++++++++++++ +++++++++++++++++++++
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N 3,894,000 +++++++++++++++++ +++++++++++++++++++
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o ++++++++++++++++++++ ++++++++++++++++
Z 3,893,500 ++++++++++++++++++++ ++++++++++++++++
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�D +++++++++++++++++++++++++++++++++++++
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3,893,000 +++++++++++++++++++++++++++++++++++
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3,892,500 +++++++++++++++++++++++++++
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3,892,000 +
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578,000 578,500 579,000 579,500 580,000 580,500 581,000 581,500 582,000
UTM Easting(Zone 17,NAD83 m)
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4.5 Modeling Results
Table 4-3 summarizes the normalized modeling impacts for the Perdue Ansonville mill. Maximum
concentrations occur at or near the properly boundary. The impacts from the normalized modeling
analysis were then used to calculate an allowable facility-wide emission rate that demonstrates
compliance with the formaldehyde AAL.
Electronic copies of model input and output files will be provided via secure FTP upon request from
DAQ modeling staff.
Table 4-3. Normalized Modeling Results
j Impact Impact Location Modeled
Modeled Averaging Date UTM-E UTM-N Concentration
Source Period (YRMODYHR) (m) (m) (pg/m3)
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BLDGFUG 1-Hour 17120508 580,159.8 3,893,997.4 805.84
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Table 4-4. Allowable Emission Rate
Averaging AAL Allowable
TAP Period (µg/m) Emission Rate Units
Formaldehyde 1-Hour 150 1.46 lb/hr
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5. GENERAL FACILITY PERMIT APPLICATION FORMS
This section contains DEQ permit application forms for the general facility and proposed changes.
FACILITY FORMS
Form A— Facility (General Information)
Form A2 — Emission Source Listing
Form A3 — 112(r) Applicability Information
Form D1 — Facility-wide Emissions Summary
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FORM A
GENERAL FACILITY INFORMATION
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A
..NOTE APP,, ATION 3iUILL NOT BE pRf3GE5SE[3 WI[FLOUT THE F.P.LLOW,IrdG
ppropriate Number of Copies of Application Application Fe
Local Zoning Consistency Determination
(new or modification only) A e(please check one option below)
l7 Responsible Official/Authorized Contact Signature ❑ P.E.Seal(if required) ❑ Not Required ❑ ePayment ❑ Check Enclosed
Check submitted under separate cover
GENEi2ALaN00"ATlON.
Legal Corporate/OwnerName: Perdue Agribusiness LLC
Site Name: Perdue Agribusiness Ansonville
Site Address(911 Address)Line 1: 2755 Old Hwy 52 West
Site Address Line 2:
City: Ansonville State: North Carolina
Zip Code: 28007 County: Anson
A INFO
ANN
Responsible Official/Authorized Contact: Invoice Contact:
Namelritle: Sharon Clark,SVP Regulatory Affairs&Compliance Name/Title: Joey Baggett
Mailing Address Line 1: 6906 Zion Church Road Mailing Address Line 1: 242 Perdue Road
Mailing Address Line 2: Mailing Address Line 2;
City: Salisbury State: MD Zip Code: 21802-1637 City: Cofieid State: NC 27922
Primary Phone No.: 410-341-2509 Fax No.: Primary Phone No.: 252'348'4383 Fax No.:
Secondary Phone No.: I Secondary Phone No.:
Email Address: Sharon.clarklcbperdue.com Email Address: IOBV.baggett(C>)perdue.COm
Facility/Inspection Contact., Permit/Technlca/Contact:
Name/Title: Joe Potts Name/Title: JOOY Baggett
Mailing Address Line 1: 2765 Old Hwy West Mailing Address Line 1: 242 Perdue Road
Mailing Address Line 2: Mailing Address Line 2:
City: Ansonville State: NC Zip Code: 28007 City: Cofield State: NC Zip Code: 27922
Primary Phone No.: 704-590-3050 Fax No.: Primary Phone No.: 252-348-4383 Fax No.:
Secondary Phone No.: Secondary Phone No.:
Email Address: ioe.potts Perdue.com Email Address: [e-mail]
WPLICA fIOFI(SBE#NG A)IADE FQEt
t... .
❑ New Non-permitted Facility/Greenfield Modification of Facility(permitted) ❑ Renewal Title V ❑ Renewal Non-Title V
❑ Name Change ❑ Ownership Change ❑ Administrative Amendment ❑ Renewal with Modification
y Fri�tTY cCAsll'IcATIanrAF7EI?APPLIcIC? Hseck On. oriel,_ ;.
❑ General ❑ Small ❑ Prohibitory Small 0 Synthetic Minor ❑ Title V
y Fa�ILITv PI „t srte:INFORIi�ItlWl~l,
Describe nature of(plant site)operation(s): Feed Mill
Facility ID No. 400039
Primary SIC/NAICS Code: 204 1424910 Current/Previous Air Permit No. 0749SR09 Expiration Date:0613012025
Facility Coordinates: Latitude: 35.149769 Longitude: - 0.120064
Does this application contain ***If yes,please contact the DAQ Regional Office prior to submitting this application.`•`
❑ YES 10 NO (See Instructions)
confidential data?
, ..,.. _ 1?ERSON OR"FIRIII THAT P>tEPARED'APPLICAI"ION_" 77
Person Name: Dana W.Norvell Firm Name: Trinity Consultants
Mailing Address Line 1: One Copley Parkway Mailing Address Line 2: Suite 205
City: Morrisville State: NC Zip Code: 27660 County: Wake
Phone No.: [phone] Fax No.: Email Address: dnorvell trin ityconsultants.com
_.. S"IGNATURE OF RESPON5rB1 E flFF101AuAu fH(3F21zEl CONTACT''' ...
Name(typed): Sharon Clark Title: // SVP Regulatory Affairs&Compliance
X Signature(Blue Ink): Date: Ad������
Attach Additional Sheets As Necessary Page 1 of 2
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FORM A (continued, page 2 of 2)
GENERAL FACILITY INFORMATION
REVISED 09/22/16 NCDEO/Divislon of Air Quality-Application for Air Permit to ConstrucUOperate A
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SETA Ny
(Company Name)hereby formally requests renewal of Air Permit No.
There have been no modifications to the originally permitted facility or the operations therein that would require an air permit since the last permit was issued.
Is your facility subject to 40 CFR Part 68"Prevnetion of Accidental Releases"-Section 112(r)of the Clean Air Act? ❑ YES ❑ NO
If yes,have you already submitted a Risk Manage Plan(RMP)to EPA? ❑ YES ❑ NO Date Submitted:
Did you attach a current emissions inventory? ❑ YES ❑ NO
If no,did you submit the inventory via AERO or by mail? ❑ Via AERO ❑ Mailed Date Mailed
In accordance with the provisions of Title 15A 2Q.0513,the responsible official of (Company Name)
hereby formally requests renewal of Air Permit No. (Air Permit No.)and further certifies that:
(1) The current air quality permit identifies and describes all emissions units at the above subject facility,except where such units are exempted under the
North Carolina Title V regulations at 15A NCAC 2Q.0500;
(2) The current air quality permit cits all applicable requirements and provides the method or methods for determing compliance with the applicable
requirements;
(3) The facility is currently in compliance,and shall continue to comply,with all applicable requiremetns. (Note:As provided under 15A NCAC 2Q.0512
compliance with the conditions of the permit shall be deemed compliance with the applicable requirements specifically identified in the permit);
(4) For applicable requirements that become effective during the term of the renewed permit that the facility shall comply on a timely basis;
(5) The facility shall fulfill applicable enhanced monitoring requirements and submit a compliance certification as required by 40 CFR Part 64.
The responsible official(signature on page 1)certifies under the penalty of law that all information and statements provided above,based on information and belief
formed after reasonable inquiry,are true,accurate,and complete.
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New Facility Name:
Former Facility Name:
An official facility name change is requested as described above for the air permit mentioned on page 1 of this form. Complete the other sections if there have been
modifications to the originally premitted facility that would requie an air quality permit since the last permit was issued and if{her has been an ownership change
associated with this name change.
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By this application we hereby request transfer of Air Quality Permit No. from the former owner to the new owner as described below.
The transfer of permit responsibility,coverage and liability shall be effective (immediately or insert date.) The legal ownership of the
facility described on page 1 of this form has been or will be transferred on (date). There have been no modifications to the originally
permitted facility that would require an air quality permit since the last permit was issued.
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Signature of New(Buyer)Responsible Official/Authorized Contact(as typed on oacie 11:
X Signature(Blue Ink):
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Date:
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New Facility Name:
Former Facility Name:
Signature of Former(Seller)Responsible Official/Authorized Contact:
Name(typed or print):
Title:
. X Signature(Blue Ink):
Date:
Former Legal Corporate/Owner Name:
In lieu of the seller's signature on this form,a letter may be submitted with the seller's signature Indicating the ownership change
N. EIPPLIG,l1TF IS AMEI+(G?ME
. .< .
Describe the requested administrative amendment here(attach additional documents as necessary):
Attach Additional Sheets As Necessary Page 2 of 2
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FORMS A2, A3
EMISSION SOURCE LISTING FOR THIS APPLICATION-A2
112r APPLICABILITY INFORMATION-A3
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to ConstrucVOperate A2
I:I EMISSION SOURCE LISTING:New,Modified,Previously Unpermitted, Replaced,Deleted
EMISSION SOURCE EMISSION SOURCE ONTROL DEVIC CONTROL DEVICE
ID NO. DESCRIPTION ID NO. DESCRIPTION
13 M£Nll b,'.,,'3E
i,
N/A
.aa..., i. \ •• .Ikted� �!ll fi)Qf1ta .'-.�� �
No,1 3 storage silos CD-3 Fabric Filter
No.C Pneumatic Truck Receiver CD-5 Fabric Filter
No.H Truck loadout operation with three sided,roofed enclosure NA NA
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No.J Mineral Additive Mixing and Handling System NA NA
.III,, u�Y �1\ �.. ,.• � ,• � .- •. � e '\�3�a � y \r
N/A
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Is your facility subject to 40 CFR Part 68"Prevention of Accidental Releases"-Section 112(r)of the Federal Clean Air Act? ❑ Yes G No
If No,please specify in detail how your facility avoided applicability: The site does not store Part 68 chemicals above reporting thresholds.
If your facility is Subject to 112(r),please complete the following:
A. Have you already submitted a Risk Management Plan(RMP)to EPA Pursuant to 40 CFR Part 68.10 or Part 68.150?
❑Yes ❑ No Specify required RMP submittal date: If submitted,RMP submittal date:
B. e. Are you using administrative controls to subject your facility to a lesser 112(r)program standard?
❑Yes ❑ No If yes,please specify:
C. List the processes subject to 112(r)at your facility:
MAXIMUM INTENDED
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PROCESS DESCRIPTION PROCESS LEVEL(1,2,or 3) HAZARDOUS CHEMICAL INVENTORY LBS)
Attach Additional Sheets As Necessary
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FORM D1
FACILITY-WIDE EMISSIONS SUMMARY
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operat D1
Adffi.. KlIT-FE 1,10A
EXPECTED ACTUAL
EMISSIONS POTENTIAL EMISSION OTENTIAL EMISSION
(AFTER CONTROLS/ (BEFORE CONTROLS/ (AFTER CONTROLS/
LIMITATIONS) LIMITATIONS) LIMITATIONS)
AIR POLLUTANT EMITTED tons/ r tons/ r tons/ r
PARTICULATE MATTER(PM)
PARTICULATE MATTER<10 MICRONS(PM10)
PARTICULATE MATTER<2.5 MICRONS(PM2.5)
SULFUR DIOXIDE(SO2)
NITROGEN OXIDES(NOx)
j CARBON MONOXIDE(CO)
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VOLATILE ORGANIC COMPOUNDS(VOC) 4.28
LEAD These are project emissions onl .
GREENHOUSE GASES(GHG)(SHORT TONS)
OTHER
EXPECTED ACTUAL
EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSION
(AFTER CONTROLS/ (BEFORE CONTROLS/ (AFTER CONTROLS/
LIMITATIONS) LIMITATIONS) LIMITATIONS)
HAZARDOUS AIR POLLUTANT EMITTEC CAS NO. tons/ r tons/ r tons/ r
Methanol 0.67 0.67
Formaldehyde 0.30 0.30
These are project emissions only.
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iR.Rt3L NT: MtuCC ) MATI(?` WISE
EMISSION RATE(TPER)IN 15A NCAC 2Q.0711 MAY REQUIRE AIR DISPERSION MODELING. USE NETTING FORM D2 IF
NECESSARY.
Modeling Required?
TOXIC AIR POLLUTANT EMITTED CAS NO. Ib/hr lb/day Ib/year Yes No
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Formaldehyde 50-00-0 0.069 1.66 607.068 X
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These are project emissions onl .
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COMMENTS:
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6. SOURCE SPECIFIC PERMIT APPLICATION FORMS
This section contains the NCDAQ permit application forms for the proposed emission units
EMISSION UNIT FORMS
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Form B - Specific Emissions Source Information
Form B9 - Emission Source (Other)
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Perdue Ansonville, NC
Construction Permit Application 6-1 Trinity Consultants
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FORM B
SPECIFIC EMISSION SOURCE INFORMATION (REQUIRED FOR ALL SOURCES)
REVISED 09/221 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate B
!` EMISSION SOURCE DESCRIPTION: No.J EMISSION SOURCE ID NO: NO.J
CONTROL DEVICE ID NO(S): NA
OPERATING SCENARIO 1 OF 1 EMISSION POINT(STACK)ID NO(S): Fugitive
DESCRIBE IN DETAIL THE EMISSION SOURCE PROCESS(ATTACH FLOW DIAGRAM):
Mixer(70 tons/hr). These sources emit VOC including formaldehyde,methanol,and propionic acid due the use of Termin-8 in the feed
! mix for pathogen control.
TYPE OF EMISSION SOURCE(CHECK AND COMPLETE APPROPRIATE FORM B1-69 ON THE FOLLOWING PAGES):
❑ Coal,wood,oil,gas,other burner(Form 131) ❑ Woodworking(Form 64) ❑ Manuf.of chemicals/coatings/inks(Form 67)
❑ Int.combustion engine/generator(Form 62) ❑ Coating/finishing/printing(Form B ❑ Incineration(Form 138)
❑ Liquid storage tanks(Form 63) ❑ Storage silos/bins(Form 66) Other(Form 69)
START CONSTRUCTION DATE: DATE MANUFACTURED:
MANUFACTURER/MODEL NO.: EXPECTED OP.SCHEDULE: HR/DAY DAY/WK WK/YR
IS THIS SOURCE SUBJEC LJ NSPS(SUBPARTS?): N/A LJ NESHAP(SUBPARTS?):_N/A
PERCENTAGE ANNUAL THROUGHPUT(%): DEC-FEB 25 MAR-MAY 25 JUN-AUG 25 SEP-NOV 25
CRIMU tLifTANT
SOURCE 01 EXPECTED ACTUAL POTENTIAL EMISSIONS
EMISSION (AFTER CONTROLS/LIMITS) IEFORE CONTROLS/LIMIT (AFTER CONTROLS/LIMITS)
AIR POLLUTANT EMITTED FACTOR Ib/hr tons/yr. Ib/hr tons/yr Ib/hr tons/yr
PARTICULATE MATTER(PM)
PARTICULATE MATTER<10 MICRONS(PM10)
PARTICULATE MATTER<2.5 MICRONS TM2.5)
SULFUR DIOXIDE(S02)
NITROGEN OXIDES(NOx)
CARBON MONOXIDE(CO)
VOLATILE ORGANIC COMPOUNDS(VOC) 0.98 4.28 0.98 4.28
LEAD
OTHER
SOURCE 01 EXPECTED ACTUAL POTENTIAL EMISSIONS
JEMISSION (AFTER CONTROLS/LIMITS) iEFORE CONTROLS/LIMIT (AFTER CONTROLS/LIMITS)
HAZARDOUS AIR POLLUTANT CAS NO. FACTOR Ib/hr tons/yr Ib/hr tons/yr Ib/hr tons/yr
Methanol 0.163 0.67 0.153 0.67
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Formaldehyde 1 0.07 0.30 0.07 0.30
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C
OF EXPECTED ACTUAL EMISSIONS AFTER CONTROLS/LIMITATIONS
EMISSION
TOXIC AIR POLLUTANT CAS NO. FACTOR Ib/hr lb/day Ib/yr
Formaldehyde 50-00-0 0.07 1.66 607
Attachments:(1)emissions calculations and supporting documentation;(2)indicate all requested state and federal enforceable permit limits(e.g.hours of operation,
emission rates)and describe how these are monitored and with what frequency;and(3)describe any monitoring devices,gauges,or test ports for this source.
IPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE B1 THROUGH B9 FORM FOR EACH SOU
Attach Additional Sheets As Necessary
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FORM B9
EMISSION SOURCE (OTHER)
REVISED 09/22/16 NCDEO/Division of Air Quality-Application for Air Permit to Construct/Operat 139
EMISSION SOURCE DESCRIPTION: Mixer EMISSION SOURCE ID NO: NO.J
CONTROL DEVICE ID NO(S): NA
OPERATING SCENARIO: OF EMISSION POINT(STACK)ID NO(S):Fugitive
DESCRIBE IN DETAIL THE PROCESS(ATTACH FLOW DIAGRAM):
Mixer(70 tons/hr). These sources emit VOC including formaldehyde,methanol,and propionic acid due the use of Termin-8 in the
feed mix for pathogen control.
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MATERE, I,,,,„P,lQCSS G-4,
a1 }("�, MAX.DESIGN REQUESTED CAPACITY
TYPE UNITS CAPACITY(UNIT/HR) LIMITATION(UNIT/HR)
Feed ingredients tons 70 N/A
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MAX.DESIGN REQUESTED CAPACITY
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TYPE UNITS APACITY(UNIT/BATC LIMITATION(UNIT/BATCH)
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MAXIMUM DESIGN(BATCHES/HOUR):
REQUESTED LIMITATION(BATCHES/HOUR): (BATCHES/YR):
FUEL USED: N/A ITOTAL MAXIMUM FIRING RATE(MILLION BTU/HR): N/A
MAX.CAPACITY HOURLY FUEL USE: IREQUESTED CAPACITY ANNUAL FUEL USE:
COMMENTS:
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APPENDIX A. EMISSION CALCULATIONS
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Perdue Ansonville, NC
Construction Permit Application A Trinity Consultants

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PERDUE ANSONVILLE BLENDING OPERATION
POTENTIAL FORMALDEHYDE&METHANOL EMISSIONS
Process Emissions from Use of Termin-8
Value Units Description Basis
613,200 tons r Annual Feed Production Rate Maximum annual rate
70.00 tons hr Hourly Feed Production Rate Maximum hourly rate
6 lb/ton Termin-B a e per ton of feed Provided by Plant
33% Percent Formaldehyde in Termin-8 Provided by Termin-8 supplier Anitox
138.60 Ib hr Formaldehyde added to feed Mass Balance 6lb/ton*0.33*34.25 tons hr
1,214,136 Ib r Formaldehyde added to feed Mass Balance 6lb/ton*0.33*300,000 tons r
Percent Formaldehyde Released(99.95%
0.05% bound in feed) Provided by Termin-8 supplier Anitox
Formaldehyde added to feed(lb/hr)*%Formaldehyde
Ij 0.071b hr Hourly Formaldehyde emissions Released
Formaldehyde added to feed(lb/yr)*%Formaldehyde
607 Ib r Annual Formaldeh de emissions Released
0.30 tons r Annua Forma eye emissions Annual emissions Ib r 20001b ton
13% Percent Methanol in Termin-B Provided by Termin-8 supplier Anitox
0.28% Percent Released Provided by Termin-8 supplier Anitox
Hourly Feed Production Rate(tons/hr)*6lb/ton Termin-B
0.153 Ib hr Methanol emissions *13%Methanol"%a Methanol Released
Annual Feed Production Rate(tons/yr)*6lb/ton Termin-8
1339 Ib r Methanol emissions *13%Methanol*%Methanol Released
0.67 tons r Methanol emissions Annual emissions Ib r 20001b ton
9% Percent Pro Ionic acid in Termin-8 Provided by Termin-8 supplierAnitox
2.0% Percent Released Assum [ion
0.76 Ib hr
Annual Feed Production Rate(tons/yr)*6lb/ton Termin-8
6623 lb r Pro ionic acid emissions "9%Pro Acid*%Pro Acid Released
'I 3.31 tons Pr( aci emissions Annual emissions lb r 20001b ton
'i 8,569 Ib r 70C emissions Formaldehyde+Methanol+pro Ionic acid emissions
4.26 tons r IVUL emissions jAnnual VOC emissions Ib r 20001b ton
Notes:
Uncontrolled emissions=Controlled emissions
Emissions calculated using mass balance approach.
Emissions are assumed to be emitted in the mixing area where Termin 8 is added.
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Emissions Summary
Pollutant Emissions b hr Emissions
Formaldeh de 0.07 0.30
Methanol 0.153 0.67
VOC 0.98 4.28
LB/HR TPER i Formaldehyde Obstructed TPER t
Y ( )
0.04
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Above Modeling Threshold
YES
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Page 1 of 1
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APPENDIX B. VENDOR INFORMATION
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Perdue Ansonville, NC
Construction Permit Application B Trinity Consultants
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,SNIT
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SECURITY THROUGH SCIENCE"
Nov 10,2021
T+1 678 376 1055
F+1 678 376 1413
Jaclyn Maysanito
Regional Environmental Manager www.anitox.com
'i Perdue Agribusiness
North Arnedca
Global Headquarters
1055 Progress Circle
Lawrenceville,GA 30043
Termin-8®—Formaldehyde and Environmental Protection Agency(EPA)Reporting Regulations
Dear Jaclyn Mays:
In answer to your question regarding the reporting requirements under EPA's Clean Air Act for formaldehyde in
Anitox's product Termin-8®Liquid, please find the following information to assist you in determining the reporting
requirements for your company.Termin-8®Liquid is a premixture of aqueous formaldehyde, propionic acid, d-
limonene, and surfactant.Termin-8 Liquid contains 33%w/w formaldehyde.When treated with Termin-8®Liquid at
label rate(61bs/ton),feed and feed ingredients are guaranteed to be free from Salmonella for 21 days post
application according to the Code of Federal Regulations—see 21 CFR Sec.573.460 Formaldehyde here:
https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=573.460
a
Formaldehyde solution (CAS No. 50-00-0)is included in EPA's list of Hazardous Air Pollutants (HAP)and is subjected
to state reporting if emissions meet or exceed threshold limits.
When applied to feed,formaldehyde is bound chemically to the proteins in the feed to form a "Schiff
it base". Despite this strong binding, our analytical chemistry allows us to extract and recover 98%of the
formaldehyde that has been applied to feed. Using just this analytical data,this means we can calculate that the
maximum amount of formaldehyde that could be emitted is 2%(as 98%is confirmed analytically to remain in the
feed). I underline could because in the second calculation I will explain that in reality much less than the 2% is
released from the feed. However,we do prefer to explain this step wise approach to calculate emissions as it is
often sufficient on its own to be able to determine if a facility is likely to comply with their PTE threshold.
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Anitox have also performed detailed emission studies both in our laboratory and also commercial feed mills in
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Europe and in the US. In these studies,we measured formaldehyde following forced ventilation of treated feed,
and also in working feed mills testing the extraction stacks,vents,top of feed bins etc.Those results showed that
the amount of formaldehyde actually lost to the environment was in fact<0.05%of applied*.
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The following is an estimate of the Potential To Emit(PTE)from your Ansonville, NC facility treating 114,000
tons/year at 6 lbs/ton Termin-8® Liquid.
Formaldehyde estimate using Emissions data
j1. Estimated amount of feed treated per year=114,000 tons
2. Max amount of Termin-8®Liquid that can be used is 6 lb/ton (line 1 x 6 Ib/ton)=684,000 Ibs

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3. Potential amount of formaldehyde used in a calendar year(line 2 x 33%) =225,720 Ibs
4. Typical percent of Termin-8 lost as atmospheric emissions=0.05%*
5. Total estimated emissions of formaldehyde in calendar year(line 3 x line 6)=113 lbs.
Formaldehyde hourly Emissions calculations
When calculating the amount of formaldehyde released per hour while running at a rate of 60 tons per hour and
jtreating at 6 Ibs per ton,the following estimated emissions are expected.
1. Amount of feed treated per hour=60 tons
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2. Max amount of Termin-8® Liquid that can be used is 6 lb/ton (line 1 x 6 lb/ton)=360 Ibs/hour
3. Potential amount of formaldehyde used in an hour(line 2 x 33%)=119 Ibs
4. Amount of formaldehyde released=0.05%*
5. Potential To Emit(PTE of formaldehyde assuming 0.05% is released (line 3 x 0.05%)=0.06 Ibs/hour
North Carolina Unobstructed Toxics Permitting Emission Rate (TPER)for formaldehyde is 0.16 Ibs/hour of acute
irritants. Using the PTE or the 0.05%emissions from Line 5 above,you would be below the 0.16 Ibs/hour threshold.
We hope this information is helpful to you, and please let us know if we can be of further assistance.
I� Sincerely,
Nathan Freeman
Quality Assurance Manager
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*This data is considered proprietary/confidential however it can be submitted directly to your state
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authorities/regulators upon request.
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APPENDIX C. MODELING PROTOCOL
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Avoca, Merry Hill
Minor Modification Permit Application C Trinity Consultants
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A.1
North Carolina Modeling Protocol Checklist
The North Carolina Modeling Protocol Checklist may be used in lieu of developing the traditional written modeling plan for North
Carolina toxics and criteria pollutant modeling. The protocol checklist is designed to provide the same level of information as
requested in a modeling protocol as discussed in Chapter 2 of the Guideline for Evaluating the Air Quality Impacts of Toxic Pollutants
in North Carolina. The modeling protocol checklist is submitted with the modeling analysis.
Although most of the information requested in the modeling protocol checklist is self explanatory,additional comments are provided,
where applicable, and are discussed in greater detail in the toxics modeling guidelines referenced above. References to sections,
tables,figures,appendices,etc.,in the protocol checklist are found in the toxics modeling guidelines.
INSTRUCTIONS: The modeling report supporting the compliance demonstration should include most of the information listed
below. As appropriate,answer the following questions or indicate by check mark the information provided or action taken is reflected
in report.
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FACILITY INFORMATION
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Name: Perdue Agribusiness Consultant(if applicable):
j Ansonville Mill Trinity Consultants
Facility ID: 0400039 One Copley Parkway
Suite 205
Address: 2755 Old Hwy 52 West Morrisville, NC 27560
Ansonville, NC 28007
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Contact Name: Joey Bdggett Contact Name: Jonathan Hill
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Phone Number: 252-348-4383 Phone Number: 919-462-9693
Email: Joe .Ba99
ett Perdue.com Email:
[e-mail]
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GENERAL
Description of New Source or Source/Process Modification: provide a short description of the new or modified X
source(s)and a brief discussion of how this change affects facility production or process operation.
Source/Pollutant Identification: provide a table of the affected pollutants,by source, which identifies the source
type (point, area, or volume), maximum pollutant emission rates over the applicable averaging period(s), and, for X
point sources,indicate if the stack is capped or non-vertical(C/N).
Pollutant Emission Rate Calculations: indicate how the pollutant emission rates were derived(e.g.,AP-42,mass X
balance,etc.)and where applicable,provide the calculations.
Site/Facility Diagram: provide a diagram or drawing showing the location of all existing and proposed emission
sources, buildings or structures, public right-of-ways, and the facility property (toxics) / fence line (criteria X
pollutants) boundaries. The diagram should also include a scale, true north indicator, and the UTM or
latitude/longitude of at least one point.
Certified Plat or Signed Survey:a certified plat(map)from the County Register of Deeds or a signed survey must X
be submitted to validate property boundaries modeled.
Topographic Map: A topographic map covering approximately 5km around the facility must be submitted. The
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facility boundaries should be annotated on the map as accurately as possible.
Cavity Impact Analysis:No cavi analysis is required if using AERMOD.See Section 4.2
X
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February 2014
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Background Concentrations(criteria pollutant analyses only):Background concentrations must be determined for
each pollutant for each averaging period evaluated. The averaged background value used (e.g., high, high-second- NA
high,high-third-high,etc.)is based on the pollutant and averaging period evaluated.The background concentrations
are added to the modeled concentrations, which are then compared to the applicable air quality standard to
determine compliance.
Offsite Source Inventories (criteria pollutant analyses only): Offsite source inventories must be developed and
modeled for all pollutants for which onsite sources emissions are modeled in excess of the specific pollutant NA
significant impact levels (SILs) as defined in the PSD New Source Review Workshop Manual. The DAQ AQAB
must approve the inventories.An initial working inventory can be requested from the AQAB.
SCREEN LEVEL MODELING
Model: The latest version of the AERSCREEN model must be used.The use of other screening models should be NA
;i approved by NCDAQ prior to submitting the modeling report.
Source / Source emission parameters: Provide a table listing the sources modeled and the applicable source NA
emission parameters. See NC Form 3—Appendix A.
Merged Sources: Identify merged sources and show all appropriate calculations. See Section 3.3 NA
GEP Analysis: See Section 3.2 and NC Form 1—Appendix A NA
jTerrain: Indicate the terrain modeled: simple(Section 4.4),and complex(Section 4.5 and NC Form 4—Appendix
A). If complex terrain is within 5 kilometers of the facility,complex terrain must be evaluated. Simple terrain must
include terrain elevations if any terrain is greater than the stack base of any source modeled. NA
Simple: Complex:
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Meteorology: Refer to Section 4.1 for AERSCREEN inputs. NA
Receptors: AERSCREEN—use shortest distance to property boundary for each source modeled and use sufficient NA
range to find maximum(See Section 4.1 i)and ')). Terrain above stack base must be evaluated.
Modeling Results: For each affected pollutant,modeling results should be summarized, converted to the applicable NA
ji averaging period (See Table 3), and presented in tabular format indicating compliance status with the applicable
AAL, SIL,or NAAQS. See NC Form S5—Appendix A.
Modeling Files: Either electronic or hard copies of AERSCREEN out ut must be submitted. NA
REFINED LEVEL MODELING
Model: The latest version of AERMOD should be used, and may be found at
http://www.epa.gov/scram001/dispersion_prefrec.htm. The use of other refined models must be approved by X
NCDAQ prior to submitting the modeling report.
Source / Source emission parameters: Provide a table listing the sources modeled and the applicable source X
emission parameters. See NC Form 3-Appendix A.
GEP Analysis: Use BPIF-Prime with AERMOD.
Cavity Impact Analysis: No separate cavity analysis is required when using AERMOD as long as receptors are X
laced in cavity susceptible areas. See Section 4.2 and 5.2.
Terrain: Use digital elevation data from the USGS NED database (http://seamless.usgs.gov/index.php). Use of
other sources of terrain elevations or the non-regulatory Flat Terrain option will require prior approval from DAQ X
AQAB.
Coordinate System: Specify the coordinate system used (e.g., NAD27, NAD83, etc.) to identify the source,
building, and receptor locations. Note: Be sure to specify in the AERMAP input file the correct base datum wGS$4
(NADA)to be used for identifying source input data locations. Clearly note in both the protocol checklist and the
modeling report which datum was used.
[See
eceptors: The receptor grid should be of sufficient size and resolution to identify the maximum pollutant impact. X
Section 5.3.
III
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Meteorology: Indicate the AQAB, re-processed,5-year data set used in the modeling demonstration:
P Y g
(See Section 5.5 and Appendix B)
AERMOD Monroe/Greensboro 2014-2018
If processing your own raw meteorology,then pre-approval from AQAB is required. Additional documentation X
files(e.g.AERMET stage processing files)will also be necessary. For NC toxics,the modeling demonstration
requires only the last year of the standard 5 year data set(e.g.,2005)provided the maximum impacts are less than
50%of the applicable AAL(s).
Modeling Results: For each affected pollutant and averaging period, modeling results should be summarized and
presented in tabular format indicating compliance status with the applicable AAL, SIL or NAAQS. See NC Form X
!� R5 -Appendix A.
Modeling Files: Submit input and output files for AERMOD. Also include BPIP-Prime files, AERMAP files, X
DEM files,and any AERMET input and output files,including raw meteorological data.
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tFebruary 2014
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